NY Times Obituary Confuses Justice John Marshal Harlan I and II

Tuesday will be the New York Times The DOJ published an obsequie for Philip B. Heymann. Heymann was an attorney who served as a lawyer in the DOJ. The article was originally published as follows:

Following his graduation from Harvard Law School (in 1960), he was appointed as Associate Justice John M. Harlan’s clerk. He is best known for his many disdainful opinions in cases that limited civil liberties.

Woops. Woops.

A previous version of this obituary incorrectly identified the Supreme Court associate justice for whom Mr. Heymann worked as a young lawyer graduate. It also mischaracterized the justice’s standing on the bench. John M. Harlan II was the one he clerked for, and not John M. Harlan, Justice Harlan’s grandfather. It was not his grandson who was known for his many dissensions in civil rights cases.

Here’s the conclusion of the article:

He graduated from Harvard Law School, 1960. After that, he worked as a clerk at the Supreme Court, Associate Justice John M. Harlan II.

It is the original punctuation error.

That’s why it is so refreshing to learn that the Solicitor general was not willing to make that mistake. Plessy should have been overruled on 1897. We will continue to discuss this matter later.